Need to return call by / at/between and

. Signature: Project No.: 

### 0 317.0 2 .005.510 Page 1 of 5

Project Name: 

### DMR20 1 3 

## CBI?

Yes

No TELEPHONE CALL RECOR D

Incoming

Outgoing Date: 

### 5/13/15 Time: 

### 3 :3 0 am

pm

Company Name: 

### Mountain State Carbon ERG Staff Name: 

### Kimberly Bartell

Contact Name: 

### Patrick Smith Contact Phone Number: 

### ( 740) 283

- 5542

General Subject: 

### 2013 DMR Cyanide Discharges for Mountain State Carbon



## TOPICS DISCUSSED AND ACTION TAKEN

Patrick Smith: 304

- 527

- 5676

Patrick.smith@mscarbonllc.com

I spoke with Mr. Smith in January 2015 about the facility ’ s PCB discharges . I followed up via email in May

2015 to discuss the facility ’ s cyanide discharges. See email correspondence below.Need to return call by / at/between and

. Signature: 

### Email Correspondence with Mountain State Carbon:

From: Kimberly Bartell

To: Patrick.smith@mscarbonllc.com

Date: Thu 5/28/15 2:49 PM

Subject: RE: 2013 DMR Clarification for Cyanide Discharges

Hi Pat,

Thank you for your response. I will let you know if we have any further questions.

Thanks again,

Kim

-------------------------------------- Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: Patrick Smith

To: Kimb erly Bartell

Date: Thu 5/28/15 12:49 PM

Subject: RE: 2013 DMR Clarification for Cyanide Discharges

Kim,

My responses are below your questions, in BOLD BLUE

. Let me know if you have any further questions.

Pat

From: Kimberly Bartell [ mailto:Kimberly.Bartell@erg.com ]

Sent: Friday, May 15, 2015 12:44 PM

To: Smith, Patrick

Subject: RE: 2013 DMR Clarification for Cyanide Discharges

Hi Pat,

Thank you for getting back to me so quickly. I took a closer look at the data this morning. Can yo u please confirm my assumptions

below based on the 2013 permit are correct? I would like to make sure I’m summarizing your facility information correctly.

1) Outfall 005 was renamed outfall 004, mentioned in your email below. The 2013 permit sets a report o nly limit for WAD

cyanide and total cyanide. This has changed from the 2008 permit which had WAD cyanide limits for this outfall. The data in

my previous email is for WAD cyanide for this outfall, not total cyanide.

MSC Response: Correct. WAD CN limits b egan on 1/15/2011 in the 2008 permit at outlet 005, and your

previous 2013 data for 005 is WAD CN.

2) Outfall 205 was renamed outfall 006, mentioned in your email below. The 2013 permit sets a revised limit for WAD cyanide

and total cyanide. This has also cha nged from the 2008 permit which had permit limits for only total cyanide for this outfall.

The data below is for total cyanide.

MSC Response: Correct.

Do you know why the permit limit was changed for outfall 005 (now 004) in the 2013 permit? Additionall y, is data missing for

October and November 2013 for outfall 005 (now 004)? Or was that data not submitted?

MSC Response: The change in outfall names and limits reflect our installation of an effluent diffuser for

outlet 2 05 and its removal from outlet 005 to directly discharge. Outlet 205 via the diffuser is now called outlet 006, and 005

was changed to outlet 004, reflecting that it is now almost entirely non

- contact cooling water. Since 2013, cyanide sampling is

only r equired quarterly at outlet 004, which in the quarter you are asking about means only December data was collected.

Upon re

- reviewing the data I believe I was comparing WAD cyanide data to total cyanide data which led me to believe discharges had

increased . Since you provided more background, I do not believe my comparison was accurate. Again, thank you for getting back toNeed to return call by / at/between and

. Signature: me and providing detailed responses. It is helpful in ensuring we describe the discharges from the facility correctly in the 2015 Annua l

Review Report.

Thanks,

Kim

From: Kimberly Bartell

To: Patrick.smith@mscarbonllc.com

Date: Fri 5/15/15 12:44 PM

Subject: RE: 2013 DMR Clarification for Cyanide Discharges

Hi Pat,

Thank you for getting back to me so quickly. I took a closer look at the data this morning. Can you please confirm my assumpt ions

below based on the 2013 permit are correct? I would like to make sure I’m summarizing your facility information correctly.

1) Outfall 005 was renamed outfall 004, mentioned in your email below. The 2013 permit sets a report only limit for WAD

cyanide and total cyanide. This has changed from the 2008 permit which had WAD cyanide limits for this outfall. The data in

my previous email is for WAD cyanide for this outfall, not total cyanide.

2) Outfall 205 was renamed outfall 006, mentioned in your email below. The 2013 permit sets a revised limit for WAD cy anide

and total cyanide. This has also changed from the 2008 permit which had permit limits for only total cyanide for this outfall

. The data below is for total cyanide.

Do you know why the permit limit was changed for outfall 005 (now 004) in the 2013 p ermit? Additionally, is data missing for

October and November 2013 for outfall 005 (now 004)? Or was that data not submitted?

Upon re

- reviewing the data I believe I was comparing WAD cyanide data to total cyanide data which led me to believe discharges h ad

increased. Since you provided more background, I do not believe my comparison was accurate. Again, thank you for getting back to

me and providing detailed responses. It is helpful in ensuring we describe the discharges from the facility correctly in th e 2015 Annual

Review Report.

Thanks,

Kim

From: Patrick Smith

To: Kimb erly Bartell

Date: Thu 5/14/15 10:05 AM

Subject: RE: 2013 DMR Clarification for Cyanide Discharges

Kim,

I got a chance to take an initial look at the data. Generally it agrees with our DMRs, with a few caveats/clarifications:

ITEM 1 Please confirm the 2013 DMR cyanide discharges in the table below.

1) All data (flow and cyanides) appears to be the monthly averages of all measurements. Therefore I suggest the dates be

expressed in month/year, not month/day/year.

2) The outlet 005 data cyan ides are for WAD cyanide, NOT total cyanide. WAD cyanide is a subset of total cyanide and

normally significantly lower than total cyanide for our wastewaters. All other cyanides you have displayed are total

cyanides.

3) Outlet 205 cyanide data is expressed in kg/day, vs. the lb/day in our DMR. The conversion to kg/day appears to be correct.

4) Outlet 006 cyanide data appears to be incorrect. Correct data is shown in 5) below.

5) Data that is incorrect is, by outlet:

a. 004: December 2013 cyanide data should be 0.0 13 mg/L, not 0.018.

b. 005: July 2013 flow data (by my rounding convention) should be 9.39 MGD, not 9.38.

c. 006: October 2013 total cyanide data should be 3.4 mg/L, not 1.67.

d. 006: October 2013 flow data (by my rounding convention) should be 0.578, not 0.57.

e. 006: November 2013 total cyanide data should be 4.5 mg/L, not 2.24.

f. 006: December 2013 total cyanide data should be 2.1 mg/L, not 1.0064.

ITEM 2 Please provide a description of the outfalls at your facility including which outfalls are internal outfal ls.Need to return call by / at/between and

. Signature:

The 2013 permit changed the naming of the outlets. Outlet 005 (non

- contact cooling water) was renamed outlet 004. Wastewater

treatment plant outlet 205 was renamed outlet 006. All discharge directly to the Ohio River.

ITEM 3 Please provide a copy of your current NPDES permit if available

. Permit is attached to this email.

ITEM 4 The cyanide discharges have increased since 2011. What factor(s) have contributed to the overall increase ?

I cannot validate this statement, based on an initial re view of my DMR data. Are you comparing the WAD Cyanide data

from outlet 005 with total cyanide data at another location? Now that I’ve provide a bit more background, I suggest you take a

look at this conclusion and if you still believe it true, please pr ovide data that has led you to it, and we can go from there.

Thanks

Pat

From: Kimberly Bartell

To: Patrick.smith@mscarbonllc.com

Date: Wed 5/13/15 12:39 PM

Subject: 2013 DMR Clarification for Cyanide Discharges

Hi Pat,

I spoke with you a few months ago about your facility’s 2013 TRI PAC Discharges. We are continuing to review 2013 data as part of

the 2015 Annual Review and I have a few follow up questions for you regarding 2013 DMR cyanide discharges at Mountain State

Carbon. I’ve included my additional questions below.

1. Please confirm the 2013 DMR cyanide discharges in the table below.

2. Please provide a description of the outfalls at your facility including which outfalls are internal outfalls.

3. Please provide a copy of your current NPDES permit if available.

4. The cyanide discharges have increased s ince 2011. What factor(s) have contributed to the overall increase?

Outfall Date Cyanide

Concentration or

Quantity Cyanide

Units Flow

(MGD)

004 12/31/2013 0.018 mg/L 13.2

005 1/31/2013 0.0021 mg/L 7.58

005 2/28/2013 0.0021 mg/L 6.52

005 3/31/2013 0.0026 mg/L 13.53

005 4/30/2013 0.0016 mg/L 14.25

005 5/31/2013 0.0026 mg/L 13.5

005 6/30/2013 0.0009 mg/L 12.6

005 7/31/2013 0.0029 mg/L 9.38

005 8/31/2013 0.002 mg/L 8.68

005 9/30/2013 0.0021 mg/L 10.01

006 10/31/2013 1.67 mg/L 0.57

006 11/30/2013 2.24 mg/L 0.606

006 12/31/2013 1.0064 mg/L 0.6

205 1/31/2013 4.39 kg/day 0.57

205 2/28/2013 4.17 kg/day 0.6

205 3/31/2013 3.76 kg/day 0.58

205 4/30/2013 5.44 kg/day 0.59

205 5/31/2013 12.6 kg/day 0.5

205 6/30/2013 6.34 kg/day 0.69

205 7/31/2013 3.76 kg/day 0.73

205 8/31/2013 4.98 kg/day 0.65

205 9/30/2013 4.036 kg/day 0.7

We appreciate your help in confirming if the above data are accurate, or if there are units errors in the DMR data. Please call me at

(517) 515

- 1721 if you have any questions. If you would like to speak directly with EPA regarding this request, you can contactNeed to return call by / at/between and

. Signature: William F. Swietlik of EPA's Office of Water/Engineering Analysis Division by phone at (202) 566

- 1129 or by

email: swietlik.william@epa.gov

.

Thank you,

Kimberly

-------------------------------------- Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721